Alternative Capitalis, LLC
71 Commercial St, #254
Boston, MA 02109
(551) 258-3476
[email protected]
Business Continuity Plan
Background
While it is recognized it is not possible to create a plan to handle every possible eventuality, it is the intent
of this firm to set up a framework to be used in most likely of scenarios. It is also the intent that this
framework provide guidance as to how to respond should an unforeseen situation occur.
Business Description
Alt Capitalis conducts business in equity, fixed income, and other securities; it does not hold customer
funds or securities. All transactions are sent to our designated brokerage firm, which executes our orders,
compares them, allocates them, clears and settles them. Our designated brokerage firm also maintains our
clients’ accounts, can grant clients access to them, and delivers funds and securities.
Emergency Information
Firm Contact Person
Our firm’s emergency contact persons is:
Dustin Latham
(603) 748-1489
[email protected]
There is only one owner and IAR of the firm, Dustin Latham, therefore there are no additional contact
persons. Please see your respective brokerage firm contacts below if our emergency contact person is unreachable.
Support Services
In the event of an emergency, the following is a list of support services and the methods by which they
may be contacted:
Emergency Services (EMS): 911 for emergency, non-emergency (617) 466-4662
Fire Department: (617) 466-4855
Police Department: (617) 466-4600
http://www.ci.chelsea.ma.us/Public_Documents/ChelseaMA_EmMan/index
This information will be updated in the event of a material change, and our Chief Compliance Officer
(CCO) will review the plan on an annual basis.
Firm Policy
Our firm’s policy is to respond to a Significant Business Disruption (SBD) by safeguarding employees’
lives and firm property, making a financial and operational assessment, quickly recovering and resuming
operations, protecting all of the firm’s books and records, and allowing our clients to transact business. In
the event that we determine we are unable to continue our business, we will assure clients prompt access
to their funds and securities.
Significant Business Disruptions (SBDs)
Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only our firm’s
ability to communicate and do business, such as a fire in our building or the death of a key member of the
firm. External SBDs prevent the operation of the securities markets or a number of firms, such as a
terrorist attack, a city flood, or a wide-scale, regional disruption. Our response to an external SBD relies
more heavily on other organizations and systems, such as the brokerage firm(s) we use.
Approval and Execution Authority
Dustin Latham, a supervisory person, is responsible for approving the plan and for conducting the
required annual review. The CCO has the authority to execute this BCP.
Plan Location and Access
Our firm will maintain copies of its BCP and annual reviews, and all changes that have been made to it.
A physical copy of the BCP will be stored with the company’s Written Policies and Procedures Manual,
which is kept available at www.altcapitalis.com or available upon request. The electronic copy will be
stored as a PDF file on the firm's server in a folder entitled "Business Continuity Plan." This will be
available at www.altcapitalis.com
Our brokerage firm contacts:
Shareholders Service Group, Inc.
9845 Erma Road, Suite 312
San Diego, CA 92131-1084
Phone (800) 380-7370
www.ssginstitutional.com
Folio Institutional
Toll-free: 1 (888) 485-3456
Fax: (703) 649-6288
www.folioinstitutional.com
Email: [email protected]
8180 Greensboro Drive, 8th Floor, McLean, VA 22102
Interactive Brokers LLC
1 (866) 694-2757
www.interactivebrokers.com
Headquarters: One Pickwick Plaza, Greenwich, CT 06830 USA
Office Locations
Our office address and phone number are:
100 Heard St Unit 346, Chelsea, Massachusetts, 02150. (551) 258-3476
We engage in client servicing, order taking and entry at this location.
Alternative Physical Location(s) of Employees
In the event of an SBD that makes it impossible or impractical to use any or all of the company offices,
we will move our staff from affected offices to the closest of our unaffected office locations.
If none of our other office locations is available, we will move the firm operations to:
83 South Ridge Road
Bradford, New Hampshire
(603) 748-1489
An additional alternate location is:
18 E Elm St
#1014
Chicago, IL 60611
(603) 748-1489
Clients’ Access to Funds and Securities
Our firm does not maintain custody of clients’ funds or securities, which are maintained at our brokerage
firm. In the event of an internal or external SBD, if telephone service is available, our investment adviser
representatives will take customer orders or instructions and contact our brokerage firm on their behalf,
and if our Web access is available, our firm will post on our Website that clients may access their funds
and securities by contacting them.
Data Back-Up and Recovery (Hard Copy and Electronic)
Our firm maintains its primary hard copy books and records and its electronic records at:
100 Heard St Unit 346, Chelsea, Massachusetts, 02150
(551) 258-3476
Dustin Latham is responsible for the maintenance of these books and records. Our firm maintains the
following document types and forms that are not transmitted to our brokerage firm: Investment Policy
Statements, Client Contracts and other related documents.
The firm backs up its electronic records daily by online digital backup, and keeps a copy at Microsoft One
Drive for Business and at least Quarterly backup to external hard drive located at 100 Heard St Unit 346,
Chelsea, Massachusetts, 02150
In the event of an internal or external SBD that causes the loss of our paper records, we will physically
recover them from our back-up site. If our primary site is inoperable, we will continue operations from
our back-up site or an alternate location. For the loss of electronic records, we will either physically
recover the storage media or electronically recover data from our back-up site, or, if our primary site is
inoperable, continue operations from our back-up site or an alternate location.
Operational Assessments
Operational Risk
In the event of an SBD, we will immediately identify what means will permit us to communicate with our
clients, employees, critical business constituents, and regulators. Although the effects of an SBD will
determine the means of alternative communication, the communications options we will employ will
include our Website, telephone voice mail, secure e-mail, etc. In addition, we will retrieve our key
activity records as described in the section above, Data Back-Up and Recovery (Hard Copy and
Electronic).
Mission Critical Systems
Our firm’s “mission critical systems” are those that ensure client communication, access to client
accounts and trading systems. More specifically, these systems include the office computer systems.
We have primary responsibility for establishing and maintaining our business relationships with our
clients. Our brokerage firm provides the execution, comparison, allocation, clearance and settlement of
securities transactions, the maintenance of customer accounts, access to customer accounts, and the
delivery of funds and securities.
Our brokerage firm contract provides that our brokerage firm will maintain a business continuity plan and
the capacity to execute that plan.
Our brokerage firm represents that it backs up our records at a remote site. Our brokerage firm represents
that it operates a back-up operating facility in a geographically separate area with the capability to
conduct the same volume of business as its primary site. Our brokerage firm has also confirmed the
effectiveness of its back-up arrangements to recover from a wide scale disruption by testing.
Recovery-time objectives provide concrete goals to plan for and test against. They are not, however, hard
and fast deadlines that must be met in every emergency situation, and various external factors surrounding
a disruption, such as time of day, scope of disruption, and status of critical infrastructure—particularly
telecommunications—can affect actual recovery times. Recovery refers to the restoration of clearing and
settlement activities after a wide-scale disruption; resumption refers to the capacity to accept and process
new transactions and payments after a wide-scale disruption. Our brokerage firm has the following SBD
recovery time objectives: recovery time period of critical, core trading functions [within 6 hours]; and
critical, non-core trading functions [within the 24-72 hours] following a disruption.
Our Firm’s Mission Critical Systems
Trading
Currently, our firm enters trades by recording them on paper and electronically and sending them to our
brokerage firm electronically or telephonically. Alternatively, we place customer orders by fax, etc.
In the event of an internal SBD, we will enter and send records to our brokerage firm by the fastest
alternative means available. In the event of an external SBD, we will maintain the order in electronic or
paper format, and deliver the order to the brokerage firm by the fastest means available when it resumes
operations. In addition, during an internal SBD, we may need to refer our clients to deal directly with our
brokerage firm for order entry.
Client Account Information
We currently access client account information via the brokerage firm website. In the event of an internal
SBD, we would access client information via fax correspondence, alternate phone systems, etc.
Alternate Communications with Clients, Employees, and Regulators
Clients
We now communicate with our clients using the telephone, e-mail, our Website, fax, U.S. mail, and in
person visits at our firm or at the other’s location. In the event of an SBD, we will assess which means of
communication are still available to us, and use the means closest in speed and form (written or oral) to
the means that we have used in the past to communicate with the other party. For example, if we have
communicated with a party by e-mail but the Internet is unavailable, we will call them on the telephone
and follow up where a record is needed with paper copy in the U.S. mail.
Employees
We now communicate with our employees using the telephone, e-mail, and in person. In the event of an
SBD, we will assess which means of communication are still available to us, and use the means closest in
speed and form (written or oral) to the means that we have used in the past to communicate with the other
party.
Regulators
We communicate with our regulators using the telephone, e-mail, fax, U.S. mail, and in person. In the
event of an SBD, we will assess which means of communication are still available to us, and use the
means closest in speed and form (written or oral) to the means that we have used in the past to
communicate with the other party.
Regulatory Reporting
Our firm is subject to regulation by the state of Massachusetts. We now file reports with our regulators
using paper copies in the U.S. mail, and electronically using fax, e-mail, and the Internet. In the event of
an SBD, we will check with the SEC and/or other relevant regulators to determine which means of filing
are still available to us, and use the means closest in speed and form (written or oral) to our previous
filing method. In the event that we cannot contact our regulators, we will continue to file required reports
using the communication means available to us.
Regulatory Contact:
Securities Division
Secretary of the Commonwealth
Massachusetts Securities Division
One Ashburton Place, 17th Floor
Boston, MA 02108
Telephone: (617) 727-3548
Fax: (617) 248-0177
Death of Key Personnel
The following personnel are identified as “Key Personnel” without which it would be difficult or
impossible to continue operating the firm and/or properly service clients:
Dustin Latham, Day-to-day operations.
If some event made it impossible for any person listed above able to continue to service the firm, Alt
Capitalis would implement the following: Clients of the firm are provided contact information for any and
all custodians who hold their accounts, Clients should be able to obtain similar services from another
RIA, and their custodial accounts would not depend on the well-being of the key personnel at this RIA.
Updates and Annual Review
Our firm will update this plan whenever we have a material change to our operations, structure, business
or location or to those of our brokerage firm. In addition, our firm will review this BCP annually, to
modify it for any changes in our operations, structure, business, or location or those of our brokerage
firm.
Approval & Signature
Supervisor Approval
Approve the firm’s Business Continuity Plan (BCP) program by signing below.
I have approved this Business Continuity Plan as reasonabl y designed to enable our firm to
meet its obligations to clients in the event of a Significant Business Disruption.
Signed:
Officer Name and
Title:
Dustin Latham, CEO, CCO
Dustin Latham
2/10/2016
Supervisor Signature
Date